Case Digest (G.R. No. 212256) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Farida Yap Bitte and the Heirs of Benjamin D. Bitte v. Spouses Fred and Rosa Elsa Serrano Jonas (775 Phil. 447, G.R. No. 212256, December 9, 2015), the petitioners sought Supreme Court review of the Court of Appeals’ reversal of the Regional Trial Court (RTC), Branch 13, Davao City, which had favored the Jonas spouses. The dispute arose over a lot at 820 corner Jacinto Street and Quezon Boulevard, Davao City (“subject property”), originally titled to Rosa Elsa Serrano Jonas (Rosa Elsa) and covered by a Special Power of Attorney (SPA) in favor of her mother, Andrea C. Serrano, to sell. In May 1996, Andrea’s son, Cipriano Serrano, solicited an advance of ₱600,000 from the petitioners, Farida and Benjamin Bitte, purportedly on behalf of Rosa Elsa. The petitioners also paid for Rosa Elsa’s return airfare from Australia to conclude the sale. On October 10, 1996, Rosa Elsa revoked the SPA. Despite this, Andrea executed a Deed of Absolute Sale on February 25, 1997 in favor of the Bi Case Digest (G.R. No. 212256) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background of the Dispute
- Parties and Property
- Petitioners: Farida Yap Bitte and the heirs of Benjamin D. Bitte (Spouses Bitte).
- Respondents: Spouses Fred and Rosa Elsa Serrano Jonas (Spouses Jonas).
- Subject property: Lot at 820 corner Jacinto Street and Quezon Boulevard, Davao City (initially under TCT No. T-112717 in Rosa Elsa’s name; later under TCT No. T-315273 in Ganzon Yap’s name).
- Alleged Contract of Sale and SPA
- July 19, 1985: Rosa Elsa executes a Special Power of Attorney (SPA) in favor of her mother, Andrea C. Serrano, to sell the property.
- May–September 1996: Andrea’s son, Cipriano Serrano, offers the property to Spouses Bitte; they pay advances of ₱200,000 (Sept. 3) and ₱400,000 (Sept. 10).
- Spouses Bitte pay for Rosa Elsa’s round-trip airfare from Australia for negotiation in October 1996.
- October 10, 1996: Rosa Elsa revokes the SPA; October 11: meeting with Spouses Bitte yields no sale; October 12: Rosa Elsa withdraws from transaction.
- Procedural History
- Civil Case No. 24,771-96 (Specific Performance)
- October 17, 1996: Spouses Bitte sue Rosa Elsa, Andrea and Cipriano for specific performance to compel transfer of title.
- RTC Branch 13 issues TRO (Oct. 18, 1996) and WPI (Nov. 8, 1996).
- July 30, 1999: Spouses Bitte fail to appear at pre-trial; complaint dismissed; Andrea’s sale to Bitte (Feb. 25, 1997) rendered nugatory.
- Civil Case No. 27,667-99 (Annulment and Reconveyance)
- November 16, 1999: Spouses Jonas sue to annul Andrea’s Deed of Absolute Sale (Feb. 25, 1997), cancel TCT and recover possession.
- TRO and WPI issued (Nov. 17 and Dec. 6, 1999).
- July 11, 2000: Amended complaint impleads Spouses Yap (new registered owners).
- Consolidation and RTC Joint Decision
- May 26, 2000: RTC Branch 13 consolidates both cases for joint hearing.
- April 17, 2002 & August 21, 2003: Spouses Bitte declared in default; Rosa Elsa presents evidence ex parte.
- January 18, 2007: RTC Branch 13 dismisses Case 24,771 and orders Spouses Bitte to pay Rosa Elsa ₱1,546,752.80 (balance of sale) with 12% interest (Joint Decision).
- Court of Appeals Decision and Resolution
- September 26, 2013: CA reverses RTC as to Case 27,667; declares Andrea’s Deed of Absolute Sale (Feb. 25, 1997) null and void; cancels TCT No. T-315273; reinstates TCT No. T-112717 in Rosa Elsa’s name; orders Spouses Yap to vacate.
- February 26, 2014: CA denies Spouses Bitte’s motion for reconsideration.
- Supreme Court Petition
- Spouses Bitte file a petition for review on certiorari under Rule 45, seeking reversal of the CA decision and resolution.
Issues:
- Whether the CA departed from judicial procedure by allowing an appellants’ brief filed by respondents in violation of Sec. 7, Rule 44, Rules of Court.
- Whether the CA correctly held the revocation of the SPA, despite lack of registration, enforceable against third persons.
- Whether the CA’s finding of invalidity of the Deed of Absolute Sale is supported by strong and conclusive evidence.
- Whether the CA disregarded the legal effects of the foreclosure sale in holding Spouses Bitte lacked redemption rights.
- Whether the CA erred in not recognizing Ganzon Yap as an innocent purchaser for value under the principle of indefeasibility of title.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)